Made in Canada claim in advertising: what it actually requires

Assembling here is not enough on its own. The Competition Bureau of Canada sets three conditions before it will not challenge a "Made in Canada" claim: at least 51% of the total direct costs of producing or manufacturing the good must have been incurred in Canada, the last substantial transformation of the good must have occurred in Canada, and the claim must be accompanied by an appropriate qualifying statement. "Product of Canada" is a different claim, with a threshold of 98% of total direct costs and the same last substantial transformation requirement.

The third condition is the one most Quebec manufacturers find out about late. Accounting has checked the Canadian content, nobody has heard of the statement that must accompany the claim, and the trade show banner is already printed.

This page describes the rules the Bureau publishes. It does not tell you whether your product qualifies, and it is written for a manufacturer about to put the claim into a campaign, on a product page or in a video. The wider logic is industrial marketing, and origin information belongs to the same family as the certifications covered on the manufacturer website page.

Two claims, two thresholds

The two claims do not say the same thing and do not require the same thing. Here are the conditions in the Bureau's own words.

at least 51% of the total direct costs of producing or manufacturing the good have been incurred in Canada; the last substantial transformation of the good occurred in Canada; the claim is accompanied by an appropriate qualifying statement, such as "Made in Canada with imported parts" or "Made in Canada with domestic and imported parts"Made in Canada claims, Competition Bureau Canada

at least 98% of the total direct costs of producing or manufacturing the good have been incurred in Canada; the last substantial transformation of the good occurred in CanadaProduct of Canada, Made in Canada claims, Competition Bureau Canada

The difference is easy to hold on to. "Product of Canada" is the demanding claim, at 98% of total direct costs, and it carries no qualifying statement. "Made in Canada" is the reachable one, at 51%, and it is not complete without its qualifier. A company printing "Made in Canada" alone on a site or in an ad is making the first claim without the third element the Bureau asks for.

Two points matter to a supplier selling to prime contractors. The threshold is about total direct costs of producing or manufacturing the good, not about weight, not about the number of parts, and not about the share of staff working in Quebec. And the last substantial transformation is a separate condition: it sits on top of the percentage, it does not replace it.

The qualifying statement is not fine print at the bottom of the banner

The qualifier is part of the claim. It tells the reader the good also contains imported components, which is exactly what a 51% threshold allows. Treating it as an asterisk runs against what the Bureau writes elsewhere about disclaimers.

Don't use a disclaimer to restrict, contradict or somehow negate the message to which it relates. If the main body of the advertisement creates a materially false or misleading general impression in itself, then fine print may not do much to alter the general impression in a way that ensures that consumers will not be misled.Advertising do's and don'ts, Competition Bureau Canada

The Bureau also states that a representation is assessed on both the literal meaning of the information and the general impression it creates. For a production team, that is a layout constraint before it is a legal question. A two-metre flag with the claim set large and the qualifier in 8-point type in the corner creates a general impression the corner does not correct.

The real cost: pulling the claim out of everything it was printed on

This is the part that concerns us directly, and the part we see most often. An origin claim never lives in one place. It ends up in the corporate video, in an ad headline, on the product page, in the technical PDF sent to buyers, on the booth backdrop and on the team's shirts at the show.

The day the claim has to change, here is what moves in a typical file for a manufacturer in Beauce or Saguenay.

• The plant video has to be recut, because the production manager says the claim on camera and it also appears as an on-screen title.
• B-roll has to be reshot if the offending banner is visible in the background on the shop floor.
• The booth kit has to be reprinted, on the printer's lead time, before the next industrial trade show.
• Ad creative has to be rebuilt in every format and in both languages, then re-approved.
• The spec sheets and PDFs already sent to buyers do not come back.

The regulatory exposure is real and the Bureau documents it. On the civil side, it states that a corporation faces penalties of up to the greater of $10 million, $15 million for each subsequent violation, three times the value of the benefit derived from the deceptive conduct, or 3% of annual worldwide gross revenue. In practice, though, the first invoice a manufacturer gets is a production invoice, and it arrives at the worst possible moment, a few weeks before a show or in the middle of a campaign that is working.

What to ask before the claim goes into a campaign

An origin claim is not a marketing decision. The three conditions are about total direct costs and about where the last substantial transformation happened. Those answers live in operations and in finance, not in the campaign folder.

What to demand, internally and from whoever produces your content.

• A written answer, before the shoot and before printing, naming the exact products and models the claim covers.
• The exact wording to use, qualifying statement included, and the name of the person who approved it.
• What happens when a component changes supplier. A claim that is true today is a statement about a bill of materials, and bills of materials move.
• Confirmation that the qualifier travels with the claim in every deliverable, including the 15-second cut, the square format and the French version.

The answers that should end the conversation: "we assemble here, so it is made in Canada", "everyone in the industry writes it", or a content supplier offering to put the claim in the headline without asking who verified it. A studio that puts an origin claim on screen without having seen the approved wording is selling you an asset you may have to rebuild.

What a good file looks like: the origin wording is locked before the shoot, the same way a certification number is, and it travels with the project through to the last export.

When this does not apply

If your product clearly does not reach the threshold, the right move is not to stretch a term that has a definition. It is to use the arguments you already have, and with a technical buyer they are often stronger.

Name the actual work done here. The welding and assembly done in your plant in Lévis. The testing performed before shipping. The engineering done in Quebec on a product whose components come from elsewhere. Service technicians two hours from the customer rather than three time zones away. Those statements are precise, verifiable, and they can be filmed. A buyer who has walked plants believes a production line he can see running more than a flag in the corner of a page.

There is also a case where the question does not arise at all. A subcontractor selling capacity to three prime contractors has no use for an origin claim in its communications. Those buyers already know where the plant is. What they verify is the certifications, their scope and the lead times.

One note on the vocabulary of this page. The rules cited here are about a good, a manufactured product. They are not written for a service business wanting to call itself Canadian, and I am not stretching them that far.

This page describes public rules. It is not legal advice. Have your own counsel confirm your situation before you publish.

Sources

Every French page of the Competition Bureau returned a 404 error on 23 September 2026. The rules above are written in our own words and cited to the Bureau's official English pages, fetched the same day.

• Made in Canada claims, Competition Bureau Canada, competition-bureau.canada.ca/deceptive-marketing-practices/types-deceptive-marketing-practices/made-canada-claims, fetched 23 September 2026.
• Made in Canada claims (second official address, same content), Competition Bureau Canada, competition-bureau.canada.ca/en/deceptive-marketing-practices/made-canada-claims, fetched 23 September 2026.
• Advertising do's and don'ts, Competition Bureau Canada, competition-bureau.canada.ca/en/deceptive-marketing-practices/types-deceptive-marketing-practices/advertising-dos-and-donts, fetched 23 September 2026.
• False or misleading representations, Competition Bureau Canada, competition-bureau.canada.ca/en/deceptive-marketing-practices/types-deceptive-marketing-practices/false-or-misleading-representations, fetched 23 September 2026.